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MINIMUM PRODUCT REQUIREMENTS REGARDING PRODUCT INTEGRITY WHICH

INCLUDES: SAFETY, SOCIAL COMPLIANCE, HEALTH, THE ENVIRONMENT,

PRODUCTION, ETC. FOR OWN BRAND PRODUCTS.

Version 2.5

This document is valid from April 1st, 2020

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Contents

1 General ........................................................................................................................................................... 3

1.1 Own brand definition ................................................................................................................................... 3 1.2 General minimum requirements .................................................................................................................. 3 1.3 Traceability .................................................................................................................................................. 4 1.4 Transport ..................................................................................................................................................... 4

2 Product safety ................................................................................................................................................. 5

2.1 SAR (Safety Assurance Regime) ................................................................................................................ 5 2.2 Food safety.................................................................................................................................................. 6 2.3 Non-food safety ........................................................................................................................................... 7

3 Product integrity ............................................................................................................................................ 10

3.1 FAR (Fraud Approach Regime) ................................................................................................................ 10

4 Sensory product testing ................................................................................................................................ 12 5 Sustainability ................................................................................................................................................. 13

5.1 Sustainability Policies ................................................................................................................................ 13

6 Health ............................................................................................................................................................ 18

6.1 General ...................................................................................................................................................... 18 6.2 Additives .................................................................................................................................................... 18 6.3 Allergens ................................................................................................................................................... 18 6.4 Vegetarian ................................................................................................................................................. 18 6.5 Vegan ........................................................................................................................................................ 19

7 Packaging ..................................................................................................................................................... 20

7.1 Packaging .................................................................................................................................................. 20 7.2 Specification management ........................................................................................................................ 21 7.3 Labelling .................................................................................................................................................... 21

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1 General

1.1 Own brand definition

• Products offered to customers in the supermarkets owned by or affiliated with Ahold Delhaize

businesses that fall under any of the following categories: Private Labels, fancy brands (proprietary

Private Labels that are a fantasy name owned by Ahold Delhaize), exclusive brands (not being an

international, national or regional brand), store prepared products (in-store food preparation), non-

branded products (such as bulk fruit and vegetables or no name non-food products) and promotional

items relating to the former.

• In short: every product sourced that is not an international, national or regional brand.

1.2 General minimum requirements ● The requirements stated in this Exhibit E are valid for all Albert Heijn operating companies (Albert

Heijn, Albert Heijn to go, Albert Heijn Belgium, Etos and Gall & Gall), further referred to as ‘Albert

Heijn’.

● Suppliers of own-brand products of Albert Heijn operating companies must, at all times, comply with

the requirements set in this Exhibit.

● Brokers must also comply at all times with the requirements in this Exhibit. In addition, brokers need

to comply with one of the GFSI (Global Food Safety Initiative) standards, including IFS (International

Featured Standards) brokers or BRC (British Retail Consortium).

● Suppliers must have signed the Ahold Delhaize Standards of Engagement, the Albert Heijn

Standard Buying Terms (or comparable terms from Albert Heijn operating companies) and The

Supply Framework Agreement, including the corporate responsibility appendix.

● Suppliers and products must comply with current European, as well as national legislation in the

relevant sales markets of Albert Heijn operating companies.

● In addition to complying with European legal requirements, the supplier must be able to present

documentation proving that products comply with the specific legal requirements of the countries in

which the operating companies operate.

● Production must take place in accordance with product specifications and contract terms.

● Products must, at all times, conform to specifications in the Albert Heijn product specification

database. Moreover, the product label must always conform with specifications.

● Albert Heijn must be informed immediately of any modifications and/or non-conformities in the

product, product specifications, product label, production location or production methods.

● A supplier must be available 24 hours a day, 7 days a week.

● A clear process and procedure shall be in place to ensure effective recalls or withdrawals of

products. This shall also be tested at least once a year to ensure it is updated and working in

practice. This procedure should include informing the Albert Heijn quality department and Albert

Heijn in the discussions about the product(s) involved.

● For each relevant sales market of Albert Heijn operating companies, the responsible supplier or

distributor of the product shall:

○ Register/notify the products to local authorities if needed (e.g. Poison Centre,

Cosmetic Product Notification Portal);

○ Be affiliated to recycling organizations and pay all necessary fees to meet our requirements

regarding packaging and products.

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● Do not use Polyvinyl Chloride (PVC) in products and packaging. Exceptions need to be approved

by the Albert Heijn quality department.

● Social Compliance: Albert Heijn follows the Ahold Delhaize global policy. This policy is explained in

the Ahold Delhaize Standards of Engagement (see Exhibit D of the Albert Heijn Supply Framework

Agreement). 100% of own brand suppliers in high risk countries must be audited against BSCI

(Business Social Compliance Initiative) standards (or equivalent). Audit reports must be made

available in the designated supplier database.

● Albert Heijn has the right to execute unannounced audits (direct access to production without delay).

See chapter 2 and 3 of this Exhibit for more information.

1.3 Traceability ● Products must be traceable up until the last stage of production. This means that all products shall

be traceable back to the production batch and production site within three hours, through code and

date labelling on the package.

● In relation to traceability, Albert Heijn requires all own brand suppliers and producers to be able to

trace back ingredients to the first stage of production.

1.4 Transport ● All transport, storage and distribution (excluding stores) owned or used (not fully owned) by Albert

Heijn of own brand food products (which fall under the responsibility of Albert Heijn), need to be

certified for Food Safety against a GFSI approved standard, by an independent and accredited

certifying body. Transport, storage and distribution which currently do not comply, must be able to

present a time-bound plan towards achieving this requirement.

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2 Product safety • All products delivered to Albert Heijn operating companies must be safe and fulfil all legal

requirements applicable to the specific product for each relevant sales market of Albert Heijn

operating companies.

• Quality control (QC) should be performed by the producer / manufacturer, as they have direct

influence on the manufacturing process. Albert Heijn will focus on QA activities and will conduct

supply chain risk analysis. The outcome of the risk analysis will be used in a product-supplier risk

assessment, resulting in a safety assurance regime (SAR). SAR is a risk-based approach for quality

assurance used by Albert Heijn.

2.1 SAR (Safety Assurance Regime) • Main objectives of SAR:

○ AH approach on safety assurance or safety control, based on the results of the SAR

analysis. Supplier/producer improvement in relation to product safety.

• Determining factors for SAR:

○ Intrinsic safety risk of the product itself

○ Risks within the supply chain (producer)

• SAR Categorization Matrix

• The SAR levels are determined by looking up the outcomes of the product risk and producer

risk in the Food and EBF SAR Categorization matrices below. The level of required control is

stated in each segment.

• Food SAR Categorization Matrix:

Supplier risk

1: LOW 2: MODERATE 3: HIGH →

Product risk ↓

1: LOW

SAR 1 SAR 1 SAR 3a

GFSI recognized certificate GFSI recognized certificate Agree on timeline for improvement plan including GFSI recognized higher level certificate

2: MODERATE

SAR 1 SAR 1 SAR 3a

GFSI recognized certificate GFSI recognized certificate Agree on timeline for improvement plan including GFSI recognized higher level certificate

3: HIGH

SAR 2 SAR 3b SAR 4

- GFSI recognized certificate - Tier 2 suppliers of risk ingredients must be GFSI certified

- Agree on timeline for improvement plan including GFSI recognized higher level certificate

- Agree on timeline for improvement plan including GFSI recognized higher level certificate

- Tier 2 suppliers of risk ingredients must be GFSI certified

- Production site visit according to “supplier visit checklist”

- Tier 2 suppliers of risk ingredients must be GFSI certified

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• EBF SAR Categorization Matrix:

Supplier risk → Product risk ↓

1: LOW

2: MODERATE

3: HIGH

1: LOW

SAR 1 Measures depending on product category, according to guiding document

SAR 1 Measures depending on product category, according to guiding document

SAR 2 Measures depending on product category, according to guiding document

2: MODERATE

SAR 1 Measures depending on product category, according to guiding document

SAR 2 Measures depending on product category, according to guiding document

SAR 3 Measures depending on product category, according to guiding document

3: HIGH

SAR 2 Measures depending on product category, according to guiding document

SAR 3 Measures depending on product category, according to guiding document

SAR 4 Measures depending on product category, according to guiding document

2.2 Food safety • All suppliers need to apply to the Regulation (EC) No 178/2002 laying down the general principles

and requirements of food law and specifically Regulation (EC) 852/2004 (Sanco/1955/20050/rev.3)

and Regulation (EC) No 2073/2005 on microbiological criteria for foodstuffs. In this framework, all

suppliers must identify and control the critical control points, establish and implement effective

monitoring procedures, and implement corrective actions when monitoring indicates that a critical

control point is not under control. All suppliers must keep Albert Heijn informed on regular basis

about control of critical points and report to Albert Heijn immediately if there are any irregularities

with the product supplied to Albert Heijn. Suppliers must keep Albert Heijn informed in case of a

negative outcome of food safety inspections from food safety authorities and/or certified bodies.

• All food suppliers and producers of own brand food products must be certified according to a

standard approved by Global Food Safety Initiative (GFSI). For an up-to-date list of recognized

schemes, please see: http://www.mygfsi.com/about-gfsi/gfsi-recognised-schemes.html.

• If relevant, suppliers must fulfil the specific requirements of SAR (see above).

• All suppliers must implement the following actions to ensure microbiological safety in own-brand

products:

1. All suppliers must undertake studies with regard to the growth of pathogenic microorganisms

and in particular, Listeria monocytogenes. Albert Heijn imposes additional requirements with

respect to Listeria control. Suppliers of ready-to-eat foods that can provide a growth medium for

Listeria Monocytogenes, should draw up a protocol to control it. This protocol must be submitted

for approval to the external consultancy bureau which is designated by Albert Heijn.

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2. All suppliers must adhere to microbiological food safety criteria with regards to the presence of

(a certain amount of) pathogenic microorganisms. If levels exceed these criteria, the products

are to be considered harmful to health and must be withdrawn from the market.

3. All suppliers must adhere to microbiological process hygiene criteria, which serve to verify that

the production process is controlled. When exceeding these criteria, appropriate actions should

be taken.

• Pre-farm gate production of fruit & vegetables (fresh, convenience fresh, fresh fruit juice, frozen fruit

and vegetables and fresh-cut fruit and vegetables) and aquaculture shall be certified against

GLOBALGAP or other recognized pre-farmgate schemes. For an up-to-date list of recognized pre-

farm gate schemes, please go to: http://www.mygfsi.com/about-gfsi/gfsi-recognised- schemes.html.

• For fresh F&V and fresh-cut F&V, the ‘AH protocol for Residue control’ is applicable. This system

should be incorporated as an add-on module in the GlobalGAP certification.

• Additional requirements:

o Albert Heijn will no longer accept products that are produced in ovens which do not comply with

the following guidelines:

■ The ovens have been completely sanitized and have been certified asbestos-free

or asbestos-safe by a certified independent third party.

■ The ovens have been built after 1994 and the ovens’ supplier confirms that the

ovens are asbestos-free.

■ For ovens where the asbestos has been secured architecturally, they must be

certified asbestos-safe by a certified independent third party. Additionally, these

ovens require a documented asbestos emergency plan as well as annual

inspections to ensure that the oven is asbestos-safe. These inspections must be

done by a certified independent third party.

o Irradiation is not allowed for all Albert Heijn own-brand products.

• Supplements and products with added vitamins and minerals:

o All private label supplements and private label products with added vitamins and/or minerals

need to comply with the EU REGULATION (EC) No 1925/2006 of 20 December 2006 on

the addition of vitamins and minerals and of certain other substances to foods, the Dutch

law: ‘Warenwetbesluit Toevoeging micro-voedingsstoffen aan levensmiddelen’, and the

Belgian law: ‘Koninklijk besluit van 3 maart 1992 betreffende het in de handel brengen van

nutriënten en van voedingsmiddelen waaraan nutriënten werden toegevoegd’. (included

changes stated in the ‘Koninklijk besluit van 17 september 2017).

2.3 Non-food safety • In accordance with the General Product Safety Directive 2001/95/EC, only safe products, i.e.

products that do not pose a threat to people’s health or property, may be supplied. This also means

that safety information allowing consumers to assess and protect themselves against any risks

associated with a product must be provided. The information shall be provided in the languages

used in the relevant sales markets of Albert Heijn operating companies.

PRS

• The non-food product requirements are captured in Product Requirement Sheets (PRS). The

supplier must comply with these requirements and be able to prove compliance to applicable

legislation by third party testing. All relevant testing will be provided upon request.

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The supplier is always responsible for ensuring that products comply to all the latest applicable

legislation for relevant sales markets of Albert Heijn operating companies.

REACH

• All products (including packaging) must comply to Regulation (EC) 1907/2006 (REACH), including

its annexes and list of substances of very high concern (SVHC). The use of SVHCs in products and

packaging is not allowed and shall be phased out within twelve (12) months of the date of publishing

the substance on the candidate list.

• A supplier of products classified as chemical substances or preparations shall fulfil all obligations

according to Regulation (EC) 1907/2006 (REACH) either by itself or through a so called ’Only

Representative’ within the EU. A copy of the contract with the ’Only Representative’ shall be provided

to Albert Heijn as soon as possible.

• The supplier shall provide Albert Heijn with complete and valid documentation within 10 working

days of request, stating the possible content of substances on the candidate list in products or

packaging.

Food contact materials

• Products intended to come into contact with food or which can reasonably be expected to come into

contact with food, such as kitchen equipment, cutlery and food packaging, must be manufactured in

compliance with general and detailed rules on Good Manufacturing Practice (GMP). The European

Regulation (EC) No. 2023/2006 describes requirements for the quality assurance, the quality control

system and documentation that needs to be retained. All suppliers / manufacturers shall provide

proof of GMP compliance at Albert Heijn’s request.

• Furthermore, all food contact materials must be safe and meet the requirements as laid down in

Regulation (EC) 1935/2004 on materials and articles intended to come into contact with food, and

European Regulation or national legislation regarding packaging and food utensils regulations. All

suppliers / manufacturers must provide a declaration of conformity according to the relevant

regulations.

Certification of non-food producers

• Suppliers of high-risk products shall be certified according to Ahold Delhaize accepted standards for

a relevant product category*:

○ Food & feed GMPs: 21 CFR 110 or GFSI.

○ Dietary supplement GMPs: 21 CFR 111, NSF/ANSI Standard 173, NSF GMP for Sport

Standard 306, NPA GMP Standard or UL Dietary Supplement GMP.

○ Finished pharmaceuticals GMP’s: 21 CFR 210, 211, GMP finished pharmaceuticals or UL

OTC Drug GMP.

○ Medical devices GMPs: 21 CFR 820 Device Quality System (QSR), ISO 13485, CMDCAS

(Canadian) or UL Medical Device GMP

○ Cosmetic GMPs: 21 CR 700, ISO 22716 (GMP Cosmetics) or UL Cosmetic GMP.

○ All/Various: BRC global standards for consumer products, IFS household & personal care

(International Featured Standards), SGS non-food factory assessment or HPC 420.

* for some non-food product categories, there are no audit standards available. Independent

laboratory testing requirement is only an accepted fallback scenario in those cases.

DoC

• Every product batch of non-food products delivered to Albert Heijn shall be accompanied with a

Declaration of Conformity stating:

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o The product (name, batch no. and picture of product);

o Name and address of the supplier / manufacturer;

o References to the relevant harmonized standards used, or references to the specifications

in relation to which conformity is declared (including national legislation);

o All tests done to prove compliance with relevant legislation;

o The name and address of the third-party laboratory performing the tests;

o When legally required: the notified body (name, number) that performed the EC-type

examination (description of intervention) and issued the certificate.

All suppliers / manufacturers must be able to provide test results / report upon the request of Albert

Heijn.

• Depending on SAR level for non-food batches, final random inspections according to standard

criteria of ANSI/ASQ Z1.4 (ISO 2859-1) must take place before shipping.

• Final random inspections must cover:

o Quality (appearance, performance, safety and workmanship)

o Quantity

o Packaging

o Labelling

o Shipping marks

o Transport

o Drop checks

• AQL (Acceptable Quality Level) parameters and accompanying sample plans must be agreed with

Albert Heijn before production. Inspection reports and reference samples must be available on

demand.

Cosmetic products

• All suppliers take over the responsibility of a product (from Albert Heijn / Etos), if the product is

subject to regulation (EC) 1223/2009 on cosmetic products. The complete PIF (Product Information

File) must be shared with Albert Heijn or Etos after signing of the contract and be uploaded in the

specification database (TraceOne).

Medical Devices

• The technical documentation and clinical evaluation documentation as laid out in Regulation (EU)

2017/745 and/or 2017/746 of all medical devices must be approved by a notified body. The approval

must be shared with the Quality Department and be uploaded in the product specification database

(TraceOne).

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3 Product integrity

3.1 FAR (Fraud Approach Regime) • In order to improve integrity/authenticity of our products, Albert Heijn has set up a system to predict

relevant risks. The main risk drivers included in this system are product-risk and producer-risk.

• Product-risks depends mainly on; availability, claims, price, traceability, recognizability and top 10

products vulnerable to fraud (dry herbs & spices, seafood/fish, fresh and processed meat, olive oil,

honey, fruit juices, cereals, coffee/tea, alcoholics and organic products)

• Producer risk depends on the PIA (Product Integrity Audit) score judged by a third party. Albert Heijn

is standard owner of the PIA standard. An IFS PIA standard has also been developed. AH will

gradually move to the IFS PIA standard.

• If no PIA has (yet) been executed, the default risk is set to FAR 2 (yellow).

• Depending on the FAR level a number of lab tests per year are performed by a contracted lab. These

tests are initiated by Albert Heijn. The results are always shared with both the supplier and Albert

Heijn.

Costs regarding product integrity (lab testing and PIA)

• The supplier will be charged with the costs of the lab testing.

• Albert Heijn will be charged with the costs of the Albert Heijn product integrity audits. If a producer

is audited through the IFS PIA standard, costs are for the supplier.

FAR Matrix

Producer risk

→

Product risk ↓

Low Moderate High

Low FAR 1 FAR 1 FAR 2

Moderate FAR 1 FAR 2 FAR 3

High FAR 2 FAR 3 FAR 4

FAR LEVEL impact

Category Impact

FAR 1 1. Lab testing according to planning (level 1: 1/2

√n of products once/year)

2. PIA audit by third party on AH own brand

products (once/ 4 year)

Laboratory testing by Albert Heijn contracted

laboratory: nutritional values, legal and regulatory

contaminants, label control and authenticity

checks. For non-food relevant parameters

FAR 2 1. Lab testing (level 2: √n of products once/year).

2. PIA audit by third party on Albert Heijn own-

brand products (once/3 year).

FAR 1 demands + increased lab testing and PIA

audits.

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FAR 3 1. Lab testing (level 3: 1 ½ √n of products

once/year).

2. PIA audit by third party on Albert Heijn own-

brand products. (once/2 year).

FAR 1 demands + increased lab testing and PIA

audits.

FAR 4 1. Lab Testing (level 4: 2√n of products).

2. PIA audit by third party on Albert Heijn own-

brand products (once/1 year).

3. Unannounced production site visit by QC-

manager.

4. Deep dive risk-ingredients.

FAR 1 demands + increased lab testing and PIA

audits. unannounced production site visit by QC-

manager and deep dive risk ingredients.

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4 Sensory product testing • Albert Heijn may decide to carry out product testing of its own brand products. Testing may take

place during the tender / NPD phase (before introduction) and/or when a product is already on the

shelves. It can be a stand-alone test or a comparison with a benchmark product. The tests are

initiated by Albert Heijn.

• There are two different types of product testing, and the type of test depends on the product type

and the goal of the test:

• Internal product testing (IPT); for new introductions/reformulated products/new suppliers:

o IPT is performed by an internal AH / Etos taste (test) panel

o Light specification (recipe and nutritional value in fixed format) must be available and will be

assessed as well.

• External product testing (EPT); for monitoring existing product range

o Consumer testing is performed by a research agency appointed by Albert Heijn in

accordance with the Albert Heijn test methods. If the test is not passed, improvement and a

retest may be necessary. Test reports are shared with the supplier and Albert Heijn.

o Validity of a test report varies from one to three years, depending on the importance of the

product for AH. After validity has expired, a new test is performed.

Costs regarding sensory product testing

o The supplier will be charged with the cost of an external product test.

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5 Sustainability

5.1 Sustainability Policies • The requirements on sustainability mentioned below are subject to alteration. The most up-to-date

sustainability policy is available in our specification system (TraceOne).

● Cocoa

o All Albert Heijn own brand cocoa and chocolate products, are UTZ/Rainforest Alliance

Certified[1], based upon mass balance.

o All Albert Heijn own brand products containing the equivalent of 5% or more cocoa beans

are UTZ/Rainforest Alliance Certified, based upon mass balance.

o All Albert Heijn own brand products containing less than the equivalent of 5% cocoa beans,

but cocoa and/or chocolate is an identifiable component, or cocoa and/or chocolate is part

of the name of the Albert Heijn own-brand product, should be UTZ/Rainforest Alliance

Certified, based upon mass balance.

o All Albert Heijn organic cocoa needs to be organic and Fairtrade/Rainforest Alliance/UTZ

certified.

• Coffee

o All own brand Coffee products, based upon segregation, are UTZ/Rainforest Alliance

Certified, preferably 100%. If 100% is not available then, only the highest possible content

claim is acceptable.

o All own brand Coffee products containing less than the equivalent of 5% Coffee, but at least

consisting of an identifiable component (>1%), should also be UTZ/Rainforest Alliance

Certified.

o When Coffee is part of the name of an own brand product, the coffee component should be

UTZ/Rainforest Alliance Certified. All Arabica and Robusta beans are in scope.

o All own brand Organic Coffee must also be Fairtrade or UTZ/Rainforest Alliance Certified.

Organic certification on its own is not acceptable.

*Note, in January 2018 the Rainforest Alliance merged with UTZ to have greater impact and

be a better partner to the many stakeholders they work with. A new certification program

will be published in June 2020 with audits becoming mandatory in mid-2021.

● Dairy

o At Albert Heijn, own brand dairy products originate from grazing cows (weidemelk) as much

as possible. Though this is not always possible due to landscape and/or climate. Dairy used

in Albert Heijn own brand products (milk, yogurt, buttermilk and gouda cheese) is sourced

from a closed chain of own dairy farmers and include additional requirements related to

animal welfare and the environment.

● Eggs

○ The minimum quality for Own Brand consumer eggs regarding animal welfare is Barn Egg

1 star Beter Leven keurmerk (BLK) (Better Life Label). The minimum quality accepted for

Own Brand products containing egg is barn eggs (EU Egg Code 2). Cage eggs are not

allowed in recipes with egg as an ingredient (0%).

○ The minimum requirement for food safety is IKB and KAT certification for all consumer eggs.

In 2020 IKB or KAT (or Lion Code) certification is required for all Own brand products with

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5% equal or more egg as an ingredient or 5% less but mentioned in the product name or

showing on the packaging.

○ As from 2020 we start the transition until 2024 to source all 5% equal or more egg as an

ingredient or 5% less but mentioned in the product name or showing on the packaging from

the Albert Heijn closed egg chain.

● Flowers and plants

o All flowers and plants must be 100% GlobalGAP version 4 or equivalent certified.

o All flowers and plants must be MPS-A or equivalent certified

o All flowers and plants produced in a BSCI high risk country, must be BSCI or equivalent

certified.

o We ask that suppliers consider becoming members of the Floriculture Sustainability Initiative

(FSI).

● Fruits and vegetables

o Fruit and vegetables (fresh, convenience fresh, fresh fruit juice, frozen fruit and fresh cut

F&V) are 100% GlobalGAP or equivalent certified.

o Fruit and vegetable suppliers should have a system in place to monitor and report on water-

related criteria. The system should cover processing and primary production.

• Nuts - All nuts processed in high-risk countries.

o By 2020, all our own brand nut processors should have a Business Social Compliance

Initiative (BSCI) audit or equivalent

• Nuts - Almonds, pecans, pistachios, macadamias and walnuts

o By 2020, all Albert Heijn own brand nut producers of almonds, pecans, pistachios,

macadamias and walnuts in the snack segment, cover water-related risk using a system

that can be monitored and reported. The system should cover processing and primary

production.

• Nuts - Hazelnuts

o All Albert Heijn own brand hazelnuts in the snack segment, are UTZ/Rainforest Alliance

certified, based upon mass balance.

o All Albert Heijn own brand products in the baking segment, chocolate and hazelnut pastes

containing any hazelnuts, and all other products containing the equivalent of >5% hazelnuts

are UTZ certified, based upon mass balance.

o By 2020, all own-brand products containing less than the equivalent of 5% hazelnuts, but

with hazelnuts and/or hazelnut paste as an identifiable component, or hazelnut as part of

the name of the own-brand product should also be UTZ/ Rainforest Alliance certified, based

upon mass balance.

• Packaging

○ All packaging of Albert Heijn own-brand products need to comply with Albert Heijn’s

sustainability policy for packaging. In 2025 all Albert Heijn own brand packaging must be

100% recyclable and reduced in weight by 25% (relative to 2017 levels) without harming the

primary function of packaging, which is to protect, distribute and promote the product. As

such, all revised or new products must be assessed against the sustainability policy for

packaging and document progress with regard to this. More information can be found in the

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Albert Heijn Packaging Guidelines. These are available to all suppliers, and upon request

to non-suppliers.

i. In addition, Albert Heijn has signed the Plastic Pact and CBL Brancheplan

verpakkingen which is a framework agreement between the Dutch government and

industry. In order to comply, Albert Heijn asks its suppliers to focus specifically on

implementing the following objectives, where relevant:

ii. Reduction:

● Reduce the weight of packaging where possible. Reduce any unnecessary

packaging.

● Standardize and optimize shrink and stretch films.

iii. Recyclability:

● Do not use black plastic.

● Do not use colored PET

● Do not use Polyvinyl Chloride (PVC) in products and packaging. Exceptions

need to be approved by the Albert Heijn quality department.

● Where possible, only use mono materials.

iv. Recycled Content:

● Increase the use of recycled content in packaging.

v. Wood Fiber based:

● For any wood fiber-based packaging: Use FSC or PEFC certified paper and

cardboard in primary packaging. Increase the amount of recycled paper

and cardboard in secondary packaging. Tertiary packaging is out of scope.

To monitor the achievement of our targets, we require that every supplier fill in detailed data

on composition of primary, secondary and tertiary level packaging within the product

specification database system (such as TraceOne).

● Palm oil

o Ahold Delhaize is a member of the Roundtable on Sustainable Palm Oil (RSPO) and is fully

committed to making the production of palm oil more sustainable.

o Albert Heijn’s objective is to use only RSPO certified segregated palm oil and RSPO certified

derivatives (Segregated or Mass Balance), sourced from RSPO Chain of Custody certified

suppliers, in Albert Heijn own brand products. This means that each supplier of own brand

products containing palm oil or palm kernel oil, must become an RSPO member, RSPO

Chain of Custody Certified and use RSPO certified ingredients in Albert Heijn own brand

products.

o This applies to all palm oil, palm fat, palm kernel oil and all their derivates for all food and

non-food products.

● Pork

o All fresh pork and Dutch processed pork meat is certified against the Beter Leven Keurmerk

(BLK) 1 star quality mark.

● Poultry (chicken species)

o All chicken meat and all processed chicken meat is improved to a ‘regular+’ quality

according to CBL standard ‘kip van morgen’ (chicken of tomorrow).

o All turkey meat and all processed turkey meat is improved to a ‘regular+’ quality.

● Pulp and wood

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o All Albert Heijn own-brand products made from wood, pulp or products containing pulp need

to be Forest Stewardship Council (FSC) certified, or Program for the Endorsement of Forest

Certification (PEFC) Grade A certified (only after approval of Quality Assurance

department). PEFC Grade A refers to a list of lower risk countries of origin.

o All Albert Heijn ecological paper products need to be Forest Stewardship Council (FSC)

recycled and certified according to one of the ecological schemes (e.g. EU-Flower, Nordic

Swan, Blauer Engel).

o Products made from wood/fibers from virgin tropical hard wood are not allowed.

o Albert Heijn own-brand suppliers must be able to prove that the wood (derived)

products/components delivered to Albert Heijn are not from illegal, unreported and

unregulated (IUU) sources.

● Reared/farmed and wild catch game

o Game supply chains must be transparent.

o All primary production of farmed game animals is certified by a third party according to a

Farm Quality Assurance System.

o Albert Heijn has a permanent ban on selling foie gras and meat/feathers or other by-

products from ducks/geese used for producing foie gras and selling hair or other by-products

from angora rabbits.

● Seafood

o All Albert Heijn own brand products containing seafood, and products with >5% seafood as

ingredient, or <5% but mentioned in the product name, or showing on the packaging must

be Marine Stewardship Council (MSC), Aquaculture Stewardship Council (ASC) or Global

Sustainable Seafood Initiative (GSSI) equivalent certified.

o Products for which MSC, ASC or a GSSI Certification are not available, should be assessed

by ILVO (Instituut voor Landbouw- en Visserijonderzoek), or be sourced from a credible

Fishery or Aquaculture in Improvement Project (FIP / AIP).

● South African Wines

o Albert Heijn and Gall & Gall require WIETA (Wine and Agricultural Ethical Trade

Association) ethical (or equivalent) certification for all wine originating from South Africa.

o All current farms and factories should be Wieta/BSCI (or equivalent) certified before end

2021.

o All new farms and factories should be Wieta/BSCI (or equivalent) certified.

o Small producers/farms that current supply AH/G&G may prove social compliance via a

second-party check from AH/G&G buyers on an annual basis, though these farms should

move towards certification before end 2021.

o All farms and factories with a WIETA certification without a risk rating will have gone through

a WIETA audit with risk rating (ABCD) as planned by August 2020. Until August 2021, we

accept farms/factories that have a WIETA certification without risk rating due to unforeseen

delay in implementation.

o We strive that before end 2021 all farms and factories (regardless of size) must WIETA/BSCI

(or equivalent) certified.

• Soy

o All Albert Heijn own brand meat and processed meat (pork, beef and chicken), consumer

eggs and dairy (including cheese) originates from animals which are fed with animal feed in

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which the use of South American soy is offset through the purchase of Roundtable on

Responsible Soy (RTRS) credits.

o All soy as an ingredient of own brand products is responsibly grown. ‘Responsibly grown’ in

this case refers to: soy that originates from the European Union or the United States, soy

that is Proterra certified, or South American soy for which RTRS credits are purchased to

offset volumes.

• Tea

o All own brand Tea products, based upon segregation, are UTZ/Rainforest Alliance Certified.

o All own brand Tea products containing less than the equivalent of 5% Tea leaf (camellia

sinensis) but consisting of at least an identifiable component (>1%), should be

UTZ/Rainforest Alliance Certified.

o When Tea is part of the name in the own brand product it should be UTZ/Rainforest Alliance

Certified.

o All Albert Heijn organic Tea and Albert Heijn Excellent Tea needs to be organic certified, as

well as Fairtrade or UTZ/Rainforest Alliance Certified.

o All own brand herbal infusions are UTZ/Rainforest Alliance Certified, preferably 100%. If not

available, then only the highest possible content claim is acceptable.

● Veal

○ All fresh veal is certified against the Beter Leven Keurmerk (BLK) 1 star quality mark.

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6 Health

6.1 General • Albert Heijn is actively involved in improving the health of customers by reformulating our own-brand

products.

• Food products must comply with norms set up in the Dutch governmental agreement on product

reformulation. These norms are binding for specific product groups, for sodium, saturated fat and

energy reduction. Norms are available from your sourcing manager / buyer.

• Albert Heijn has its own health policy on the following aspects and food products must comply with

the following norms:

o reduced sodium in the entire assortment;

o reduced saturated fat for specific assortments;

o reduced added sugar for specific assortments;

o no added trans fatty acids.

Norms are available from your sourcing manager / buyer.

6.2 Additives • Albert Heijn has a policy on reducing unnecessary additives in his own-brand products. This policy

focusses on a clear label, a clean label is not the goal of this policy. Food products must meet the

following policy:

o no unnecessary additives;

o no use of additives that are forbidden in accordance to the Albert Heijn policy.

Norms are available from your sourcing manager / buyer.

6.3 Allergens • The supplier is responsible for a conclusive management of allergens according to the 5 basics of

good allergen management (i.e. SimplyOK) in raw materials and in the production facility. The

allergens are listed in the Albert Heijn product specification system.

• Albert Heijn has its own labelling policy for allergens, using an allergens box and ‘free from’ logos

for gluten, lactose and milk protein. Cross-contamination is only mentioned on packaging if the

supplier is able to provide relevant evidence (analysis using the Vital 3.0 method). The complete

policy is available from the buyer or can be found in the product specification system.

6.4 Vegetarian • Albert Heijn observes the following definition of ‘vegetarian’: ingredients and additives must not be

derived from animals that had to be killed to obtain the ingredient or substance. This is an ‘all-or-

nothing’ directive. In other words, even small quantities of substances from animals killed to obtain

the substance makes the product unsuitable for vegetarians. For example, this applies to certain

flavourings, colourings and cheeses. All eggs must be barn eggs as a minimum. The pursuit should

be to not have any cross-contamination with ingredients which are obtained of killed animals. In the

case of animal products containing allergen ingredients (e.g. fish), the Vital norms are applicable. If

it is stated on the labelling of the end product that there is cross-contamination with these allergens,

the product is not considered to be vegetarian. For all other cross-contamination with animal

products, the end product must not exceed 0.1% (1 g/kg) animal ingredients.

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6.5 Vegan • Ahold Delhaize observes the following definition of ‘vegan’: To be vegan, food and other products

must not be created with the help of living animals or animal-derived products. This takes into

account production and processing steps, technical aids and additives. Albert Heijn will take into

account one step back in the production chain.

• The pursuit should be to not have any cross-contamination with animal (derived) products. In the

case of animal products containing allergen ingredients (e.g. egg, fish), the Vital norms are

applicable. If it is stated on the labelling of the end product that there is cross-contamination with

these allergens, the product is not considered to be vegan. For all other cross-contamination with

animal products, the end product must not exceed 0.1% (1 g/kg) animal ingredients.

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7 Packaging

7.1 Packaging • Articles / Packaging which are intended to be brought into contact with food, are already in contact

with food and were intended for that purpose, can reasonably be expected to be brought into contact with food or to transfer their constituents to food under normal or foreseeable conditions of use must be manufactured according to:

○ GMP EU regulation No 2023/2006

○ Framework regulation EC 1935/2004

○ Legislation on applicable specific materials

○ Directives on individual substances or groups of substances used in the manufacture of

materials and articles intended for food contact.

○ National legislation covering groups of materials and articles for which EU legislation is not

yet in place.

• Packaging must comply with Packaging and Packaging Waste directive 94/62/EC

• Each type of packaging delivered to Albert Heijn shall be accompanied with a Declaration of

Conformity stating;

o The product (name, batch no. and picture of product);

o Name and address of the supplier / manufacturer;

o The date of the declaration;

o References to the relevant harmonized standards used, or references to the specifications

in relation to which conformity is declared (including national legislation);

o All tests done to prove compliance with relevant legislation (including Commodities Act

Decree on packaging and consumer articles);

o Information about the compliance of substances subject to any restriction or specification;

o Specifications on the use of the material or article, such as: (i) type or types of food with

which it is intended to be put in contact; (ii) time and temperature of treatment and storage

in contact with the food; (iii) ratio of food contact surface area to volume used to establish

the compliance of the material or article;

o When a functional barrier is used in a multi-layer material or article, the confirmation that the

material or article complies with the requirements of Article 13(2), (3) and (4) or Article 14(2)

and (3) of 1935/2004.

• All packaging needs to comply with the Ahold Delhaize sustainability policy (reuse, reduce, recycle,

renew). Please see Sustainability Policy Packaging above.

• All packaging needs to comply with the Ahold Delhaize BPA and BPS policy.

o Due to rising concerns about the use of BPA in food packaging, food contact materials and

thermal receipt paper, Albert Heijn has decided to ban BPA and BPS in all food packaging,

food contact materials and thermal receipt paper.

o Own-brand food packaging, food contact materials and receipt paper may not contain BPA

or BPS.

o Food packaging made of polycarbonate or with an epoxy coating should be supplemented

with a test report or declaration that states that the packaging does not contain BPA or BPS.

• All packaging needs to comply with the Ahold Delhaize MOSH MOAH policy.

o Own-brand food packaging may not contain paper, paperboard or cardboard from recycled

fibers, unless the supplier can prove this recycled paper, paperboard or cardboard cannot

be a potential source of contamination by mineral oil components. This can be achieved

through the use of a functional barrier or by testing every batch of recycled material used

for packaging.

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○ Contamination with mineral oil components must be an integral part of the risk analysis of

suppliers of own-brand food products. Focus must be on raw materials, processing, finished

products and food packaging.

○ For relevant products, Albert Heijn will include testing on MOSH/MOAH in the lab monitoring

plan. In addition, suppliers will be asked to test for MOSH/MOAH as part of their risk analysis

and assurance on this topic.

○ Albert Heijn will look at additional possibilities to prevent migration of MOSH/MOAH to and

the presence of MOSH/MOAH in our Own Brand products.

• All packaging needs to comply with the Ahold Delhaize Coloured plastic packaging policy. The

following restrictions have been set for own brand plastic rigid packaging:

○ Prohibition of black colored plastic. This because these colors are not recognized in

separation plants.

○ Prohibition of colored PET as they cannot be recycled or recycled for high market value.

○ Reduction of colored plastic material since they are recycled for a low-end use

• All packaging needs to comply with the Ahold Delhaize Bioplastic policy. The following restrictions

have been set for own brand packaging:

○ Bio-based plastic is allowed in own brand packaging when recycled content cannot be

further increased, or when recycled content is not available for foodgrade packaging. Please

follow the guide of the 4-R method (reduce, reuse, recycle, renew) for reference.

○ Biodegradable plastic can be used if they have a co-benefit with the product and therefore

have the additional advantage that more organic waste is collected.

7.2 Specification management • Suppliers of Albert Heijn own-brand products are obliged to fill in the product specification system

from Albert Heijn with all requested information (including all labelling information) of these products.

All information needs to be filled in completely and within the set terms and timelines.

• All information filled in needs to match the information which is in the specification system of Albert

Heijn and on the label of the product

• Suppliers of Albert Heijn own-brand products are obliged to upload a Safety Data Sheet (SDS) for

Non-Food products in the specification system of Albert Heijn, where applicable.

• Albert Heijn joins GS1 for the identification, capturing and sharing of data.

7.3 Labelling • The labelling on products and/or packaging shall be in the language(s) used in the relevant sale

market of Albert Heijn operating companies.

• The labelling requirements from CLP-regulation (EC 1272/2008) of all own-brand products, which

are covered by this legislation, need to be written in Dutch, French and German.

• Suppliers are responsible for correct labelling.

• Raw milk soft cheese has an increased health risk for susceptible consumers. These products are

additionally labeled with a black sticker indicating ‘au lait cru’ in order to warn this consumer group.

• Suppliers are obliged to fill in the product specifications with all requested information. Nutritional

information should be based on analyses of the product and not based on general information (i.e.

Nevo table).